[Peetwo]

AVMAD DRAFT Class 5 and Sen Fawcett QON??

Via AOPA Oz:

The Aircraft Owners and Pilots Association of Australia encourages all of our members and national supporters to download the DRAFT CASA EX**/24 Instrument for Class 5 Self-Declaration and to provide your direct feedback to both the Civil Aviation Safety Authority and the Minister for Infrastructure.

DOWNLOAD THE DRAFT INSTRUMENT

Click to Download: CASA EX**/24 – Class 5 Medical Self-Declarations Exemption 2023 – DRAFT

SUBMIT YOUR FEEDBACK TO:

Pip Spence
Director of Aviation Safety
Civil Aviation Safety Authority
Email: pip.spence@casa.gov.au

Catherine King MP
Minister for Infrastructure, Transport & Regional Development
Email: Minister.King@mo.infrastructure.gov.au

BM via FB:

Included below is the DRAFT CASA Instrument for Class 5 Self-Declaration pilot medicals that has been withheld from the aviation industry - why is CASA playing games with public consultation?

Instead of seeking public consultation and feedback on their proposed Exemption Instrument, CASA have dragged the aviation industry through years of convoluted surveys and feedback questionnaires. Why?

AOPA Australia is encouraging members and industry supporters nationwide to download the draft instrument, review and provide direct feedback to both CASA and the Minister for Infrastructure.

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Sandy's comment in reply:

Sandy Reith

As you would expect from our independent regulator we are given a foolishly restrictive proposal that flies in the face of the proven USA model. Their BasicMed allows IFR, arguably the safest flying ops environment and 2721kg which allows most private twins. But here in Bureaucratalia you’ll be fine in your twin Comanche but not in your Seneca 11 or Baron. Where’s the sense in a maximum 2000kg limit of aircraft type?

Does CASA have some statistics or accident histories that they are keeping secret?

This “reform” may help some but mitigates against IFR thus reducing IFR training and the incentive for aerobatics and formation flying. More complicating disincentive.

Once again the dysfunctional model of an independent regulator outside of a regular Department with a responsible Minister shows its deplorable lack of judgement and basic commonsense. All the latter at Australia’s expense, reducing our aviation sector strength and simply CASA looking after itself.

Get away from the Westminster model of governance with Ministerial oversight and accountability and this is the inevitable result. Our democracy is the poorer and GA today is barely half (if that) the industry that it should be.
Ring write contact your fed MP and State senators.

Speaking of 'statistics or accident histories' in relation to another AVMAD act of zealotry IE the Empire Strikes Back! on Colour Defective Pilots... Again.

...I note CM's latest UP post:

As I’ve noted before, MI, the medical standards haven’t changed in years. All that changes is the people and their personal opinions in CASA.

There was a brief period of enlightenment during which CASA administered the OCVA as a ‘third tier’ test. That occurred because there was a critical mass of people who understood their job was to implement the legislated means of demonstration of compliance with the legislated medical standards. Now there’s (again) a critical mass of people who believe their job is to implement their personal opinions on the colour vision requirements of the ICAO convention.

The CAD does not simulate an operational situation in fact. Everybody knows it.

Why do the zealots nonetheless pretend it does? Because they can. They know how prohibitively stressful and expensive it is for individuals to challenge them. And the zealots will die on the stupid hill of defending the CAD when that challenge comes. (This is one of the reasons the AvMed ‘service’ metrics are abysmal. They spend so much time on their personal crusades rather than their jobs.)

Don’t be fooled into believing the ACVA is some panacea. The zealots will only take the results of the ACVA into account after the candidate has already failed the CAD and therefore been assessed as not meeting the colour perception criterion. The ACVA is just an exercise in data gathering and justification for the restrictions that will be placed on you.

The zealots’ plan is that you will have to endure the expense and inconvenience of the CAD and the ACVA. You will then be extraordinarily lucky to get a medical certificate allowing you to fly at night.

CVDPA member Simon Choice passed the OCVA and the ACVA but AvMed still imposed a CVD-related ‘restriction’ on his medical certificate. Please read that sentence as many times as is necessary to convince you that you need to start fighting for yourself along with CVDPA.

I also note that Senator David Fawcett's written QON are yet to be answered by Su_Spence and CO - I wonder why??

Question No 79

1.Mr Marcelja indicated that the information on the CASA website did not reflect the intended policy.
a.Who has a role in authorising changes to the CASA website?
b.Does CASA have a policy or approved process for ensuring due diligence is applied to check for alignment with approved policy before changes are made?
c.If the answer to b. is YES, why wasn't this process followed?

2.Ms Spence also indicated that the information was inaccurate.
a.Who drafted the information which was published on the website?
b.What steps have been / will be taken to ensure that individual employees are aware of their responsibility to curtail their personal views and support the agreed corporate policy position?

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Question 80

Providing evidence during Estimate (23 Oct 23) Dr Manderson discussed:
1. an international group of ''expert pilots and flying instructors''.
a. How many people were in the group?
b. How were the members of the group selected?
c. How many members of the group had recent (within the past 12 months) industry flying operations experience as CPL or ATPL qualified pilots?
d. How many members of the group had recent (within the past 12 months) industry experience as a flying instructor, flight examiner, approved testing officer or equivalent?
e. How many members of the group were CASA Flying Operations Inspectors?
f. How many members of the group were/are employees of CASA?

2. a meeting of colleagues from FAA, NZ, US DoD and ICAO.
a. How many of these colleagues had expertise in aviation medicine or academic/clinical fields related to the colour perception standard?
b. How many of these colleagues had expertise in aviation flying operations or flight examiners/instructors or equivalent?

3. that no medical certificates had been denied since the decision to review the operational test. This evidence was provided during a line of questions in respect of whether CASA would provide an ''unrestricted medical certificate'' to a candidate who has passed an operational test. While assertion that no medical certificates had been denied is technically correct, it is not accurate in the context of the Estimates hearing and evidence of restrictions being applied to candidates who have passed the operational test.
a. How many CVD candidates have been issued an unrestricted medical certificate since the OCVA operational test was announced by Mr Carmody??
b. How many CVD candidates have been issued an unrestricted medical certificates since the decision to review the operational test?
c. How many CVD candidates have been issued a medical certificate containing CVD related restrictions since the decision to review the operational test?
d. On what day and by what means did CASA make a public statement that the changes announced by Mr Carmody (2020) relating to CVD testing options and outcomes under CASR 67.150 (6)© were no longer going to be implemented / accepted by CASA AVMED?
e. What guidance was provided to DAMEs and CASA AVMED staff relating to changes CASA would implement during this period?

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Question 81

A senior aviation medical officer from CASA has indicated in written communication to CVD stakeholders (30 Aug 23) that:
1. ''Passing Farnsworth and or CAD test is considered equivalent to a pass for PAPI practical test, noting only those pilots with severe CVD are offered ACVA because they cannot pass the desk-based test we are accepting as proxy for PAPI - especially the CAD''.
a. In practice, this reliance on a desk-based assessment has occurred over some years regardless of a candidates flight experience (ie: many have no flight time when they do their medical). What evidence is CASA relying on to apply restrictions on a pilot who passes on operational test (regardless of flight experience) where they have demonstrated that they can correctly interpret the visual cues provided by a real PAPI in a real operational environment?
b. How many CAD testing locations are available in Australia?
c. Is it the intent of CASA to change the 2020 provisions and require a candidate to undertake the CAD before having the option for an operational test?

2. ''It is my view that in these mild to moderate groups there are potential safety concerns, borne out in the literature and accident records, but CASA will not be addressing this in the immediate future.''
a. Does CASA support the imposition of restrictions on Australian citizens based on the ''view'' of a CASA employee?
b. Does CASA support the contention that accident records prove that mild to moderate CVD pilots who have passed an operational flight test are a potential flight-safety risk?
c. Which accident records provide an evidential basis that there is a causal relationship between CVD pilots and decreased aviation safety?
d. What operational evidence did CASA rely on to decide it would no longer support the position reached under Mr Carmody that ''CASA has carefully examined all relevant safety issues and believes this new approach offers a practical alternative assessment for colour vision deficient pilots. We have listened to the views of pilots and made judgements based on research and evidence.''
e. Does CASA intend to take future measures in respect of mild to moderate CVD pilots?

3. ''Passing ACVA with severe CVD is one risk mitigation and the benefit is to allow progression to night flying and ATPL career, carrying passengers''
a. Does CASA support the contention that passing an operational test is just one step in a ''progression'' that involves a CVD pilot receiving a medical with restrictions that will be progressively reviewed and potentially removed?
b. How can this stated approach be reconciled with evidence at Estimate (23 Oct 23) that a candidate who passes an operational test will receive an unrestricted medical?

4. ''It is clear that the PAPI is not the sole safety concern here, more work needs to be done and PIR with additional budget resources to investigate safety aspects of severe CVD in the flight environment. Recognition and Reaction time in particular.''
a. Does CASA intend to provide funding to investigate other aspects of a CVD pilots performance such as recognition and reaction time?
b. What operational evidence exist to justify this approach?

Hmm...looking FWD to those QON being answered and the subsequent probing from Sen Fawcett at Additional Estimates...

MTF...P2